amount to which paragraph (1) applies shall be allocated among such companies in such manner as the Secretary may prescribe. For purposes of the preceding sentence, the term "controlled group" means any controlled group of corporations as defined in section 1563(a); except that subsections (a)(4) and (b)(2)(D) of

The amount of taxes imposed by foreign countries and possessions of the United States shall be allowed as a credit against the tax of an organization subject to the tax imposed by section 511 to the extent provided in section 901; and in the case of the tax

Chapter 1 of the Code before the provisions of section 274 become applicable. An expenditure for entertainment, to the extent it is lavish or extravagant, shall not be allowable as a deduction. The taxpayer should then substantiate such an expenditure in accordance with the rules under section 274(d). See §1.274-5. Section 274 is a disallowance provision exclusively, and does not make deductible any

(a)-(e)(3) [Reserved]. For further information, see §1.6662-5(a) through (e)(3). (e) (4) Tests related to section 482—(i) Substantial valuation misstatement. There is a substantial valuation misstatement if there is a

(a) General rule. Except as provided in §48.4222(b)-1, tax-free sales under section 4221 may be made only if the manufacturer, first purchaser, and second purchaser, as the case may be, have been registered by the Internal Revenue Service. (b) Application

provisions in this part, for any one of the following purposes: (a) Export, as authorized under 26 U.S.C. 5214(a)(4); (b) Transfer to customs manufacturing bonded warehouses, as authorized under 19 U.S.C. 1311;

with the instructions on the form. At the same time, the manufacturer shall direct his bank to effect an EFT. (Sec. 202, Pub. L. 85-859, 68A Stat. 1417 (26 U.S.C. 5703); sec. 202, Pub. L. 85-859, 72 Stat. 1423, as amended (26 U.S.C. 5741); (Aug. 16, 1954, ch

Any person who shall fail to place and keep stamps denoting the payment of the special tax as provided in section 6806 shall be liable to a penalty (not less than $10) equal to the special tax for which his business rendered him liable, unless such failure is shown to be due to reasonable cause. If such failure to comply with

(a) In general. Except as otherwise provided in paragraph (b) of this section and §25.7520-3(b), the fair market value of annuities, unitrust interests, life estates, terms of years, remainders, and reversions transferred by gift is the present value of the interests determined under paragraph (d) of this section.

certifications required in §31.3406(d)-1(b)(3) (relating to certification that the payee's taxpayer identification number is correct) and §31.3406(d)-2 (relating to certification of notified payee underreporting) within 30 days after the establishment or acquisition without subjecting the

(a) Time and place to pay. The unpaid tax required to be shown on a return filed in accordance with §301.6316-4, whether payable in whole or in part in foreign currency, is due and payable to the Director of International Operations, Internal Revenue Service, Washington, D.C. 20225, at the time the return is filed. However, see

Notes and Related Subsidiaries Effective Date of 1988 Amendment Amendment by Pub. L. 100–647 effective, except as otherwise provided, as if included in the provision of the Tax Reform Act of 1986, Pub. L. 99–514, to which such amendment relates, see section 1019(a)

(a) In generalIf the value of the aggregate foreign gifts received by a United States person (other than an organization described in section 501(c) and exempt from tax under section 501(a)) during any taxable year exceeds $10,000, such